NORTH CAROLINA BROWNFIELDS PROGRAM
ENVIRONMENTAL MANAGEMENT PLAN
This form is to be used to prepare an Environmental Management Plan (EMP) for projects in the North Carolina Brownfields Program at the direction of a project manager for the program. Prospective Developers and/or their consultants must complete and submit this form and all pertinent attachments to their project manager prior to any site earthmoving or other development related activities. For the resultant EMP to be valid for use, it must be completed, reviewed by the program, and signed by all signers at the bottom. Consult your project manager if you have questions.
GENERAL INFORMATION
Date: Click here to enter a date.
Brownfields Assigned Project Name: Click here to enter text.
Brownfields Project Number: Click here to enter text.
Brownfields Property Address: Click here to enter text.
Brownfields Property Area (acres): Click here to enter text.
Is Brownfields Property Subject to RCRA Permit? ☐ Yes ☐ No
If yes enter Permit No.: Click here to enter text.
Is Brownfields Property Subject to a Solid Waste Permit? ☐ Yes ☐ No
If yes, enter Permit No.: Click here to enter text.
COMMUNICATIONS
Prospective Developer (PD): Click here to enter text.
Phone Numbers: Office: Click here to enter text.…..Mobile: Click here to enter text.
Email: Click here to enter text.
Primary PD Contact: Click here to enter text.
Phone Numbers: Office: Click here to enter text. Mobile: Click here to enter text.
Email:
Environmental Consultant: Click here to enter text.
Phone Numbers: Office: Click here to enter text.…..Mobile: Click here to enter text.
Email: Click here to enter text.
Brownfields Program Project Manager: Click here to enter text.
Office: Click here to enter text.
Email: Click here to enter text.
Other DENR Program Contacts (if applicable, i.e., UST Section, Inactive Hazardous Site Branch, Hazardous Waste, Solid Waste): Click here to enter text.
NOTIFICATIONS TO THE BROWNFIELDS PROGRAM
Advance Notification Times to Brownfields Project Manager: Check each box to accept minimum notice periods (in calendar days) for each type of onsite task:
On-site assessment or remedial activities: Within 10 days ☐
Construction or grading start: Within 10 days ☐
Discovery of stained soil, odors, USTs, buried drums or waste, landfill, or other signs of previously unknown contamination: Within 48 hours ☐
Implementation of emergency actions (e.g. dewatering, flood, or soil erosion control measures in area of contamination, venting of explosive environments):
Within 48 hours ☐
Installation of mitigation systems: Within 10 days ☐
Other notifications as required by local, state or federal agencies to implement redevelopment activities: (as applicable): Within 30 days ☐
REDEVELOPMENT PLANS
1) Type of Redevelopment (check all that apply):
☐ Residential ☐ Recreational ☐ Institutional ☐ Commercial ☐ Office ☐Retail ☐ Industrial
☐ Other specify: Click here to enter text.
2) Summary of Redevelopment Plans (attach conceptual or detailed plans as available):
a) Do plans include demolition of structure(s)?: ☐ Yes ☐ No ☐ Unknown
b) Do plans include removal of building foundation slab(s) or pavement:
☐ Yes ☐ No ☐ Unknown
c) Provide brief summary of redevelopment plans, including demolition, removal of building slabs/pavement and other structures: Click here to enter text.
3) Which category of risk-based screening level is used or is anticipated to be specified in the Brownfields Agreement?
☐ Residential ☐ Non-residential or Industrial/Commercial
Note: If children frequent the property, residential screening levels shall be cited in the Brownfields Agreement for comparison purposes.
4) Schedule for Redevelopment (attach construction schedule):
a) Phase I start date and anticipated duration (specify activities during each phase): Click here to enter a date.
Click here to enter text.
b) If applicable, Phase 2 start date and anticipated duration (specify activities during each phase): Click here to enter a date.
Click here to enter text.
c) Additional phases planned? If yes, specify activities if known:
☐ Yes ☐ No ☐ Not in the foreseeable future ☐Decision pending
d) Provide the planned date of occupancy for new buildings: Click here to enter a date.
CONTAMINATED MEDIA
Contaminated Media (attach tabulated data summaries for each impacted media and figure(s) with sample locations):
Part 1. Soil: ☐ Yes ☐ No ☐ Suspected
Part 2. Groundwater: ☐ Yes ☐ No ☐ Suspected
Part 3. Surface Water: ☐ Yes ☐ No ☐ Suspected
Part 4. Sediment: ☐ Yes ☐ No ☐ Suspected
Part 5. Soil Vapor: ☐ Yes ☐ No ☐ Suspected
Part 6. Sub-Slab Soil Vapor: ☐ Yes ☐ No ☐ Suspected
Part 7. Indoor Air: ☐ Yes ☐ No ☐ Suspected
PART 1. SOIL – Please fill out the information below, using detailed site plans, if available, or estimate using known areas of contaminated soil and a conceptual redevelopment plan. Provide a figure overlaying new construction onto figure showing contaminated soil and groundwater locations.
1) Known or suspected contaminants in soil (list specific compounds): Click here to enter text.
2) Depth of known or suspected contaminants (feet): Click here to enter text.
3) Area of soil disturbed by redevelopment (square feet): Click here to enter text.
4) Depths of soil to be excavated (feet): Click here to enter text.
5) Estimated volume of soil (cubic yards) to be excavated (attach grading plan): Click here to enter text.
6) Estimated volume of excavated soil (cubic yards) anticipated to be impacted by contaminants: Click here to enter text.
7) Estimated volume of contaminated soil expected to be disposed of offsite, if applicable: Click here to enter text.
IMPORTED FILL SOIL
1) Will fill soil be imported to the site? ☐ Yes ☐ No ☐ Unknown
2) If yes, what is the estimated volume of fill soil to be imported? Click here to enter text.
3) If yes, what is the depth of fill soil to be used at the property? Click here to enter text.
If a range of depths, please list the range.
4) PRIOR TO ITS PLACEMENT AT THE BROWNFIELDS PROPERTY, provide plan to analyze fill soil to demonstrate that it meets acceptable standards and can be considered clean for use at the Brownfields property (Check all that apply):
☐ Volatile organic compounds (VOCs) by EPA Method 8260
☐ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☐ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury, lead, selenium and silver)
☐ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium, silver, thallium, and zinc)
☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver, thallium, and zinc)
☐ Other Constituents & Analytical Method: Click here to enter text.
☐ Known borrow material (DESCRIBE SOURCE AND ATTACH SAMPLING PROFILE): Click here to enter text.
MANAGING ONSITE SOIL
1) If soil in known or suspected areas of contamination is anticipated to be excavated from the Brownfield Property, relocated on the Brownfields Property,or otherwise disturbed during site grading or other redevelopment activities, please provide a grading plan that clearly illustrates areas of cut and fill (approximate areas & volumes are acceptable, if only preliminary data available).
2) HAZARDOUS WASTE DETERMINATION – Does the soil contain a LISTED WASTE as defined in the North Carolina Hazardous Waste Section under 40 CFR Part 261.31-261.35? ☐ Yes ☐ No
If yes, explain why below, including the level of knowledge regarding processes generating the waste( include pertinent analytical results as needed). Click here to enter text.
If yes, do the soils exceed the “Contained-Out” levels in Attachment 1 of the North Carolina Contained-In Policy? ☐ Yes ☐ No
NOTE: IF SOIL MEETS THE DEFINITION OF A LISTED HAZARDOUS WASTE AND EXCEEDS THE CONTAINED-OUT LEVELS IN ATTACHMENT 1 TO THE NORTH CAROLINA CONTAINED-IN POLICY THE SOIL MAY NOT BE RE-USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DENR HAZARDOUS WASTE SECTION RULES AND REGULATIONS.
3) HAZARDOUS WASTE DETERMINATION – Does the soil contain a CHARACTERISTIC WASTE?:
☐ Yes ☐ No
If yes, mark reason(s) why below (and include pertinent analytical results).
☐ Ignitability
☐ Corrosivity
☐ Reactivity
☐ Toxicity
☐ TCLP results
☐ Rule of 20 results (20 times total analytical results for an individual hazardous constituent on TCLP list cannot, by test method, exceed regulatory TCLP standard)
If no, explain rationale: Click here to enter text.
NOTE: IF SOIL MEETS THE DEFINITION OF A CHARACTERISTIC HAZARDOUS WASTE, THE SOIL MAY NOT BE RE-USED ON SITE AND MUST BE DISPOSED OF IN ACCORDANCE WITH DENR HAZARDOUS WASTE SECTION RULES AND REGULATIONS.
4) Screening criteria by which soil disposition decisions will be made (e.g., left in place, capped in place with low permeability barrier, removed to onsite location and capped, removed offsite):
☐ Preliminary Health-Based Residential SRGs Click here to enter a date.
☐ Preliminary Health-Based Industrial/Commercial SRGs Click here to enter a date.
☐ Site-specific risk-based cleanup level, or acceptable concentrations determined via calculated cumulative risk. Enter details of methods used for determination/explanation:
Click here to enter text.
5) Check the following action(s) to be taken during excavation and management of said soils:
☐ Manage fugitive dust from site:
☐ Yes ☐ No
If yes, describe method; If no, explain rationale: Click here to enter text.
☐ Field Screening:
☐ Yes ☐ No
If yes, describe method; If no, explain rationale: Click here to enter text.
☐ Soil Sample Collection:
☐ Yes ☐ No
If yes, describe method (e.g., in-situ grab, composite, stockpile, etc.); If no, explain rationale: Click here to enter text.
☐ Stockpile impacted soil in accordance with NCDENR IHSB protocol in the current version of the “Guidelines for Assessment and Cleanup”, and providing erosion control, prohibiting contact between surface water/precipitation and contaminated soil, and preventing contaminated runoff. Explain any variances:
Click here to enter text.
☐ Analyze potentially impacted soil for the following chemical analytes:
☐ Volatile organic compounds (VOCs) by EPA Method 8260
☐ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☐ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury, lead, selenium and silver)
☐ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium, silver, thallium, and zinc)
☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver, thallium, and zinc)
☐ Other Constituent(s) & Analytical Method(s): Click here to enter text.
☐ Proposed Measures to Obtain Pre-Approval for Reuse of Impacted Soil within the Brownfields Property Boundary
☐ Provide documentation of analytical report(s) to Brownfields Project Manager
☐ Provide documentation of final location, thickness and depth of relocated soil on site map to Brownfields Project Manager once known
☐ Use geotextile to mark depth of fill material (provide description of material)
☐ Manage soil under impervious cap ☐ or clean fill ☐
Describe cap or fill: Click here to enter text. (provide location diagram)
☐ Confer with NC BF Project Manager if Brownfield Plat must be revised (or re-recorded if actions are Post-Recordation).
☐ Other: Click here to enter text.
☐ Final grade sampling of exposed soil (i.e., soil that will not be under buildings or permanent hardscape): [if not checked provide rationale for not needing]
Provide diagram of soil sampling locations, number of samples, and denote Chemical Analytical Program with check boxes below (Check all that apply):
☐ Volatile organic compounds (VOCs) by EPA Method 8260
☐ Semi-volatile organic compounds (SVOCs) by EPA Method 8270
☐ Metals RCRA List (8) (arsenic, barium, cadmium, chromium (speciated), mercury, lead, selenium and silver)
☐ Metals –Hazardous Substance List -14 (antimony, arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, lead, manganese, mercury, nickel, selenium, silver, thallium, and zinc)
☐ Metals – EPA Priority Pollutant List – 13 (arsenic, beryllium, cadmium, chromium (speciated according to IHSB protocol), copper, mercury, nickel, lead, antimony, selenium, silver, thallium, and zinc)
☐ Pesticides
☐ PCBs
☐ Other Constituents & Analytical Method: Click here to enter text.
OFFSITE TRANSPORT & DISPOSITION OF EXCAVATED SOIL
NOTE: Unless soil will be transported offsite for disposal in a permitted facility under applicable regulations, no contaminated or potentially contaminated soil may leave the site without approval from the brownfields program. Failure to obtain approval may violate a brownfields agreement, endangering liability protections and making said action subject to enforcement. Justifications provided below must be approved by the Program in writing prior to completing transport activities.
☐ Transport and dispose of impacted soil offsite (documentation of final disposition must be sent to Brownfields Project Manager)
☐ Landfill – analytical program determined by landfill
☐ Landfarm or other treatment facility Click here to enter text.
☐ Use as Beneficial Fill Offsite – provide justification: Click here to enter text.
☐ Use as Beneficial Fill at another Suitable Brownfields Site – (Note: a determination that a site is a “Suitable Brownfields” site will require, at a minimum, that similar concentrations of the same or similar contaminants already exist at both sites, use of impacted soil as beneficial soil will not increase the potential for risk to human health and the environment at that site, and that notarized documentation of the acceptance of such soil from the property owner of the receiving site is provided to Brownfields. Provide justification: Click here to enter text.
MANAGEMENT OF UTILITY TRENCHES
☐ Install liner between native impacted soils and base of utility trench before filling with clean fill (Preferred)
☐ Last out, first in principle for impacted soils (if soil can safely be reused onsite and is not a hazardous waste), i.e., impacted soils are placed back at approximately the depths they were removed from such that impacted soil is not placed at a greater depth than the original depth from which it was excavated.
☐ Evaluate whether necessary to install barriers in conduits to prevent soil vapor transport, and/or degradation of conduit materials due to direct impact with contaminants? Result: Yes □ No □
If no, include rationale here. Click here to enter text.